March 2, 2020

North Korea sanctions activity: OFAC designates two Chinese men, delists two Russian entities

The Office of Foreign Assets Control has sanctioned two individuals from China pursuant to Executive Order 13722 and Executive Order 13694, as amended by Executive Order 13757, for supporting malicious cyber-enabled activity, and for providing support to Lazarus Group, a designated entity.  According to OFAC, Tian Yinyin and Li Jiadong, laundered nearly $100 million that was allegedly stolen through the hacking of several cryptocurrency exchanges.  According to OFAC, operators acting on behalf of the Lazarus Group, which is controlled by the Democratic People’s Republic of Korea, were behind the hack, and Tian and Li worked to conceal the origin of the currency, and to move the stolen funds through various cryptocurrency exchange accounts.   

Following these designations, all US property of the designated individuals is blocked.  Dealings by US persons involving the property of blocked or designated persons is generally prohibited, and persons who engage in certain transactions with the designated individuals may be exposed to sanctions.  Additionally, foreign financial institutions that knowingly facilitate certain transactions for or provide services to the designated individuals could be subject to U.S. correspondent account or payable-through sanctions. 

OFAC also delisted two entities that had been designated in June 2017 pursuant to Executive Order 13722 for operating in the transportation sector in North Korea.  The two companies, Independent Petroleum Company and its subsidiary, AO NNK-Primornefteproduct, have since their designation stopped exporting to North Korea and established a global compliance program.  Property previously blocked pursuant to the designations is now unblocked, and transactions with US persons are no longer prohibited.

US Dept. of the Treasury press release